Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
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